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nt 1 Filed 11/12/19 Page 1 of 19 UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK Plaintiff, CASE NO: v. DARREN K. INDYKE and RICHARD D. KAHN, in their capacities as the executors of the ESTATE OF JEFFREY EDWARD EPSTEIN, and GHISLAINE MAXWELL, Defendants. COMPLAINT BOIES $CHILLER FLEX
f, CASE NO: v. DARREN K. INDYKE and RICHARD D. KAHN, in their capacities as the executors of the ES
touched Plaintiff in an offensive and sexual manner without her consent. 81. Epstein and Maxwell's actions constitute sexual offenses as defined in New York Penal Law Article 130, including but not limited to forcible touching as defined in Article 130.52, inasmuch as Epstein and Maxwell intentionally and for
3 mentions1 same-page
Page ?Same page
nt 1 Filed 11/12/19 Page 1 of 19 UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK Plaintiff, CASE NO: v. DARREN K. INDYKE and RICHARD D. KAHN, in their capacities as the executors of the ESTATE OF JEFFREY EDWARD EPSTEIN, and GHISLAINE MAXWELL, Defendants. COMPLAINT BOIES $CHILLER FLEX
f, CASE NO: v. DARREN K. INDYKE and RICHARD D. KAHN, in their capacities as the executors of the ES
touched Plaintiff in an offensive and sexual manner without her consent. 81. Epstein and Maxwell's actions constitute sexual offenses as defined in New York Penal Law Article 130, including but not limited to forcible touching as defined in Article 130.52, inasmuch as Epstein and Maxwell intentionally and for
3 mentions1 same-page
Page ?Same page
nt 1 Filed 11/12/19 Page 1 of 19 UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK Plaintiff CASE NO: v. DARREN K. INDYKE and RICHARD D. KAHN, i in their capacities as the executors of the ESTATE OF JEFFREY EDWARD EPSTEIN, and GHISLAINE MAXWELL, Defendants. COMPLAINT 3514.011 Page 1 o
ff CASE NO: v. DARREN K. INDYKE and RICHARD D. KAHN, i in their capacities as the executors of the E
touched Plaintiff in an offensive and sexual manner without her consent. 81. Epstein and Maxwell's actions constitute sexual offenses as defined in New York Penal Law Article 130, including but not limited to forcible touching as defined in Article 130.52, inasmuch as Epstein and Maxwell intentionally and for
Sponsored
Mutual Connections (38)
Entities connected to both Richard Kahn and New York Penal
Jeffrey Epstein
PERSON32,356 w/ Richard·5 w/ New
DI
Darren Indyke
PERSON6,511 w/ Richard·3 w/ New
Martha Stewart
PERSON2,722 w/ Richard·3 w/ New
Ghislaine Maxwell
PERSON383 w/ Richard·5 w/ New
United States
LOCATION347 w/ Richard·2 w/ New
U.S. Virgin Islands
LOCATION315 w/ Richard·4 w/ New
Jes Staley
PERSON295 w/ Richard·4 w/ New
New York
LOCATION188 w/ Richard·5 w/ New
Les Wexner
PERSON113 w/ Richard·3 w/ New
Palm Beach
LOCATION112 w/ Richard·3 w/ New
Edward Jay Epstein
PERSON51 w/ Richard·3 w/ New
Kenneth Marra
PERSON40 w/ Richard·3 w/ New
David Boies
PERSON41 w/ Richard·2 w/ New
United Kingdom
LOCATION36 w/ Richard·4 w/ New
Superior Court
ORGANIZATION33 w/ Richard·3 w/ New
Alaska
LOCATION33 w/ Richard·2 w/ New
Southern District of New York
ORGANIZATION23 w/ Richard·4 w/ New
Metropolitan Correctional Center
ORGANIZATION22 w/ Richard·3 w/ New
Jay Lefkowitz
PERSON19 w/ Richard·2 w/ New
New Mexico
LOCATION16 w/ Richard·4 w/ New